Robert Taylor
Vice President, Regulatory Affairs and Licensing
X-energy
The U.S. Nuclear Regulatory Commission completed an Environmental Assessment for X-energy’s first Construction Permit Application, concluding it’s environmental review ahead of schedule with a Finding of No Significant Impact.
This might sound like regulatory jargon, but it is a genuinely historic milestone: this is the first time a commercial nuclear reactor in the United States has ever qualified for the Environmental Assessment pathway instead of requiring a multi-year Environmental Impact Statement.
The pathway itself has existed for nearly 50 years. We’re the first commercial application to use it. So, how did we get here? And how does it help deploy advanced nuclear at scale?
Here are some lessons I’ve learned from 25 years in nuclear licensing.
You Have to Do the Work
I’ve seen nuclear licensing from both sides of the table, and I’ve seen the good, the bad, and the ugly of what it takes to get a reactor licensed.
Successful applicants do a lot of early engagement as the design is maturing. Developing a nuclear reactor takes work, and there’s plenty of time to get NRC agreement and approval on key concepts of your design. The early work isn’t flashy. It’s about the details. If you get those resolved with the NRC before you’re ready to submit an application, you have already derisked a project substantially.
The good applicants take the time to do that. They work in parallel while they’re finalizing their design, and that gives them a leg up — because once you do submit your application, those details are resolved. NRC staff does not need to revisit them. X-energy started pre-application engagement in 2018, and since then submitted more than 30 technical documents to get that early alignment. Spending that time up front pays dividends substantially during the review process, and it enables the NRC to meet much more aggressive timelines.
Here’s an example:
Align on Process, Focus on Outcomes
For our Part 50 application, we are one of the first companies using a new risk-informed approach. Before submitting an application, we wanted confidence that we were using it in a manner that the NRC finds acceptable. So, we submitted a comprehensive topical report to the NRC that explicitly explains how we were implementing this new methodology, and how we would use the results.
The NRC reviewed it, approved it, and it’s now driving efficiency during the review process. Instead of spending review hours (that we are paying for) debating how we are demonstrating safety and the calculations that went into it, the focus becomes: what are the outcomes from that methodology, and why do those demonstrate that our design is safe? You’ve agreed on process. That lets you focus on results.
Efficiency is a Shared Responsibility
Our safety methodology is enhanced licensing efficiency at work. It’s not a shortcut. It’s a decision about whether you’re willing to put in extra work early to potentially accelerate the timeline. Success is not guaranteed, and that’s a risk you have to be willing to take. If you’re not successful, the first place to look is your own application.
I’ve been on the other side. I’ve been called a bottleneck, criticized, accused of impeding our country’s ability to deploy new nuclear. Laying all the blame and burden at the NRC’s feet is just misleading. Licensing efficiency is a shared responsibility between the applicant and the regulator, and that’s not unique to nuclear energy.
The NRC does own its responsibility as part of the solution, and the need for the country to move forward on deployment of new technologies. They have to adapt, and they are. I see it. But ultimately, licensing is just one piece of a much larger puzzle, and the pre-application engagement is foundational to all of it.
Engage early, engage often. X-energy did, and it’s positioned us to demonstrate something that fundamentally changes the regulatory equation.
Enhanced Safety Enables Enhanced Efficiency
The NRC sets the bar worldwide for nuclear safety. Every nuclear regulator in the world benchmarks against their standard, and is looking to the United States for guidance on how they will ultimately license these new technologies. The NRC takes that responsibility seriously, and their standards have not changed. What has changed is the technology.
Small modular reactors coming to market now like the Xe-100 have substantial benefits because of the lessons we’ve learned over the last 50 years from light-water technologies. We now have the ability to design in safety enhancements from day one that have been learned from that operating experience.
I think of it as running a track race. The hurdles stay the same height. The best athletes jump higher and get over those hurdles quicker. Think of the Xe-100 as a better athlete. We’re able to get over those hurdles easier because we’ve elevated the safety on our side. But that bar — the hurdle — has stayed exactly the same. As it should.
What We Did
NRC’s environmental review covers over 100 different impact areas. For every one of those, we had to demonstrate that we had minimal impact on the environment. A number of attributes of the Xe-100 made this possible, and were intentionally designed to minimize environmental impact:
- Helium coolant does not activate, which means it does not pick up radionuclides like water does. That minimizes an entire category of radiological environmental concern.
- Air-cooled condensers on the non-nuclear side of the plant are much less impactful than water-cooled which rely on feedwater from resources in the area.
- Smaller construction footprint, about one-quarter the size of a large light-water reactor, meaning less land disturbance, and disruption to the community and natural habitats.
- TRISO fuel pebbles encompass, in one component, many barriers to the release of radiation, and works substantially better than historical approaches to protect against the release of fission products in the unlikely event of an accident.
We’ve taken older technology concepts, and turned them into something new and commercially ready while demonstrating that it can achieve the same or better safety outcomes than the technologies operating today. For all of our early engagement, it’s the advancement of technology that has truly aided us as we move forward.
You still have to do the work.
What the NRC Did
The NRC conducted the same comprehensive environmental review required for any nuclear power plant. Their environmental and safety standards haven’t changed—they’re as rigorous as ever. What they did was invite new ways to demonstrate compliance and embrace that new technologies can meet those high standards differently.
An agency that is willing to open its mind and accept new technologies and the innovations that come with them truly becomes what they’re trying to do — an appropriate enabler of next-generation technology, deployed quickly, safely, and at scale.
A New Path for Rapid Deployment
No commercial reactor has ever been able to meet the NRC’s high bar for approval through an Environmental Assessment. We’ve now proven it can be done. We have the technology, we have the approach. Now, we have to do the work at the next site.
We’re not going to compromise or cut corners on the siting and evaluation work, but we have a construct that the NRC has approved as an acceptable way of doing this. We know that if we can demonstrate the same minimal environmental impact on future Construction Permit Applications, we can replicate this process on future projects.
The road is clear for us to do this over and over again.
Matching Pace
Nuclear licensing consists of safety review and environmental review. EA approval completes our environmental review; the safety review continues on its established 18-month timeline. At fleet-scale, with deployment of standardized reactors, safety reviews will compress significantly—focusing on site-specific factors rather than fundamental design questions. That’s a much more straightforward set of parameters.
But it also introduces a separate risk: if the environmental review doesn’t keep pace with the safety review, you lose the benefit of the streamlined safety review. If you still need to go through an extended EIS that takes 2-3 years to complete, you’re no closer to accelerating your timeline than you were before you had a standardized design.
We received EA approval in under a year. We did it by working hard, coming prepared, and doing the boring work early, because efficiency in this particular aspect of the regulatory process helps unlock a more efficient licensing process for every application that follows, and brings the environmental review in line with the Nth-of-a-kind goals required for repeatable commercial deployment.
Enhanced Predictability
Accelerating the timeline is just one piece of the puzzle. Predictability is just as important, and EA approval can accomplish both.
The primary challenge with an EIS is timeline variability across federal, state, and local agencies. There are dozens of entities, and any one can delay the project unpredictably. An Environmental Assessment is more efficient and allows for a more predictable pathway. If you can qualify, it fundamentally reorients the licensing process.
But none of this happens without the right technology, and the right policy foundation.
A Whole-of-Government Approach
Historically, nuclear has been successful when it’s backed by a whole-of-government approach. Admiral Rickover mobilized the post-WWII industrial base for naval nuclear propulsion, and gave LWRs a decade of foundational development. When energy security was threatened during the OPEC crisis, American technical leadership enabled the largest global nuclear build-out in history.
The formula works: create conditions for success and empower companies to deliver.
X-energy has seen it firsthand with the Advanced Reactor Demonstration Program: identify the most promising technology, and establish a defined, milestone-driven approach that lets the private sector do what it does best: innovate. That is what enables milestones like the first-ever EA approval to even happen.
This country needs a lot more energy, and we have a choice to make about where we want to get it from. That takes more than one company, or one government body to accomplish. Whether it’s bipartisan support in Congress, modernization efforts at the NRC, or the White House’s executive orders creating new pathways for early-stage fission technologies — the entire government is behind this.
It’s encouraging to see so much progress. I was at the NRC when many of these modernization frameworks were being developed. Leaving before seeing them through was hard, but I left for a reason.
A Brighter Future
I believe in this technology. I truly do. I worked on TRISO fuel at the very beginning of my career. I fell in love with it back then and its potential. At the NRC, I saw that in what X-energy was trying to do – the passion, the commitment to what they wanted to achieve – both as a company and for society at large.
One day, I said, “I want to be part of that. I really do.”
When I go to work, I feel like I’m making the world better for my kids. I don’t care if it’s a cliché. If there is nothing else we do as parents, making things better for the next generation, in the best way we can, is the most you can possibly ask for.
At the end of the day, I can go home, and be proud of what I did that day. Today, that meant helping establish a proven pathway for deploying advanced nuclear at the pace and scale America’s energy future demands.
Tomorrow brings new challenges. We will face them in the only way X-energy knows how: by solving for what’s next.
